T.C. Memo. 2003-164
UNITED STATES TAX COURT
JOHN PARKS TROWBRIDGE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
SABRINA MARTIN, f.k.a. SABRINA L. TROWBRIDGE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 473-01, 474-01. Filed June 4, 2003.
R determined deficiencies in tax with respect to
Ps (H and W) for the years 1991-95, as well as
additions to tax under secs. 6651(a)(1) and 6654,
I.R.C., with respect to various of those years. Ps
filed petitions for redetermination but failed to
appear at trial. R moved for default judgment with
respect to the deficiencies in tax determined against
Ps for all years and the additions to tax determined
against H for the years 1991-93. R proceeded to trial
on the issues of (1) the additions to tax determined
against W for all years, and (2) the additions to tax
determined against H for 1994 and 1995.
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